Facts:
People of the Philippines instituted three Informations dated June 3, 1983 in the Regional Trial Court, Branch 44 of Dumaguete City charging
Josue Molas with the murders of
Dulcesima Resonable,
Soledad Resonable, and
Abelardo Resonable occurring at about 6:00 o’clock in the evening of February 2, 1983 at Sitio Inas, Dobdob, Valencia, Negros Oriental. The Informations detailed multiple stab and incised wounds that caused the immediate deaths of Dulcesima and Soledad and the later death of eight‑year‑old Abelardo from multiple stab wounds, spinal cord injury and peritonitis. Molas pleaded not guilty and the three cases were tried jointly. The prosecution presented evidence that Molas was the fiance of Dulcesima and that, at dawn of February 3, 1983, Molas surrendered at Pamplona municipal hall wearing blood‑stained clothes and turned over a hunting knife he admitted using. Molas executed an extra‑judicial statement on March 10, 1983, which was taken by Patrolman Paquito Fetalvero and later translated and signed before the Municipal Trial Court judge; during trial he repudiated portions of that statement and testified that unidentified assailants were present and that he discovered the victims already wounded. The trial court found his trial testimony inconsistent and incredible, admitted Abelardo’s statement to his father as a
dying declaration, regarded Molas’s admissions to policemen as verbal admissions though the extra‑judicial confession was executed without counsel, convicted Molas on August 10, 1990 of three counts of murder, imposed three penalties of
reclusion perpetua, and ordered P30,000.00 death indemnity to the heirs of each victim; Molas appealed.
Issues:
Was Molas’s extra‑judicial confession, executed without counsel, admissible against him in evidence?; Was Abelardo’s out‑of‑court statement admissible as a
dying declaration?; Did the prosecution prove Molas’s guilt beyond reasonable doubt and properly establish the qualifying circumstance elevating the killings to murder?
Ruling:
Ratio:
Doctrine: